- 14 15. The Defendant admits paragraph xiv of the Plaintiff’s claim only to the extent that the Plaintiff and one NOEL were allowed to go after thorough investigation but denies every allegation of facts contained therein. 16. In response to paragraph xlvi and xlvii of the Plaintiff’s claim, the Defendant states that he never at any time ignored a letter written by the Plaintiff or any other person and puts the Plaintiff to the strictest proof of the allegation of facts contained in the said paragraph. 17. In further response to paragraph xlviii of the Plaintiff’s claim, the Defendant states as follows: a) The Plaintiff’s arrest was made lawfully in furtherance of an investigation to enable the DSS carry out proper investigation on allegation of impersonation of DSS officials by the Plaintiff and one SHOLA. b) The Plaintiff was at no time maltreated during and after the investigation. The offence for which he was arrested was disclosed to him instantly at the point of arrest by the Defendant. c) The Plaintiff was not arrested at mid night and taken away to any lonely area at all. d) The Defendant never blind-folded the Plaintiff/Applicant or any other person in the course of investigation carried out by it. e) The Plaintiff was never disallowed access to his lawyers, family or to any other person that came to see him. 6.0. ISSUES FOR DETERMINATION 6.1. The three areas of disagreement between the parties are: (A.) Whether or not the Plaintiff’s arrest and detention by the Defendant were lawful and justifiable? (B.) Whether the plaintiff was subjected to inhuman and degrading treatment by the defendant? (C.) Whether or not the defendant unlawfully deprived the plaintiff of his personal belongings.